November 1, 2024
The Centers for Medicare & Medicaid Services (CMS) released its 2025 final payment rule for ASCs and hospital outpatient departments (HOPD) today. Of note, CMS declined to add any of the surgical procedures requested by ASCA to the ASC Covered Procedures List (ASC-CPL) for 2025.
“This final rule is a step sideways in a time when millions of Medicare beneficiaries need CMS to advance policies that expand access to the safe, convenient and efficient care that surgery centers provide,” said ASCA Chief Executive Officer Bill Prentice. “CMS must recognize the enormous impact of rising employment and anesthesia costs, and reform outdated budget policies that shortchange ASC reimbursements so that surgery centers can better serve Medicare patients in their communities.”
CMS will continue to use the hospital market basket (HMB) as the ASC inflation update factor for 2025, although it is unclear whether that policy will continue further. This results in an effective update of 2.9 percent for ASCs—a combination of a 3.4 percent inflation update based on the HMB and a productivity reduction of 0.5 percentage points mandated by the Affordable Care Act. This is an increase of 0.3 percent from the proposed rule. Please note that this is an average and updates might vary significantly by code and specialty.
Other initial observations about the 1,734-page final rule follow. ASCA will provide additional analysis soon, including a rate calculator that allows users to determine what ASCs will be paid locally under this final rule.
Additions to the ASC-CPL
CMS finalized the addition of 21 procedures to the ASC-CPL, including 19 dental codes that were included in the proposed rule. In addition, the agency finalized the addition of the following two adipose-derived regenerative cell (ADRC) therapy codes (short descriptor in parentheses):
- 0717T (Adrc ther prtl rc tear)
- 0718T (Adrc ther prtl rc tear njx)
Changes to ASC Quality Reporting Program
Regarding the ASC Quality Reporting (ASCQR) Program, CMS finalized the adoption of the following measures:
- the Facility Commitment to Health Equity (FCHE) measure beginning with the CY 2025 reporting period/CY 2027 payment determination;
- the Screening for Social Drivers of Health (SDOH) measure beginning with voluntary reporting in the CY 2025 reporting period followed by mandatory reporting beginning with the CY 2026 reporting period/CY 2028 payment determination; and
- the Screen Positive Rate for Social Drivers of Health (SDOH) measure beginning with voluntary reporting in the CY 2025 reporting period followed by mandatory reporting beginning with the CY 2026 reporting period/CY 2028 payment determination.
“ASCA strongly supports health equity and access to care for all patients. However, this rulemaking does not make clear how the measures will address the disparities that exist or how CMS will support the facilities required to collect this information,” noted Prentice. “If these measures had been tested in the ASC setting before being proposed, let alone adopted, the Agency would have realized that the ASC setting is not the proper site of service to obtain this data.”
ASCA staff will continue to analyze the final rule in detail and provide more information to help ASC operators understand its impact on their centers soon.